SMS Mom Pop Store
By OffRoadPilots
The term mom-and-pop describes the small business entities that are independent
or family-owned, usually operates in a single location and they provide
personalized products and services to the local community. They operate with
limited capital investment, they handle small business volumes and run with
minimal numbers of employees. Typically, the shops are not franchised and only
operate at single locations. Therefore, their customers are mostly from local
communities, and products and services are more personalized. So, what does
mom-and-pop stores have in common with an aviation safety management system
(SMS)? What they have in common is that there is no value to their existence since
they do not generate measurable short-term gain.
A safety management system
does not provide accident-
free security today, and mom-
and-pop stores does not
generate short-term savings
today. A safety management
system is process control of
service provided, and a mom-
and-pop store is process
control of products and
services. SMS is not instant
gratification of process outcome, and a mom-and-pop store is not instant
gratification in short term savings. Over time, a mom-and-pop store is a long-term
money saver, while shopping at a super centers is a long-term cash saving illusion.
The reason mom-and-pop stores are in decline, is that they charge less in the long-
term, while customers spend more cash in super centers. It’s simple, someone, e.g.
customers, are paying for the super centers to be build and operated. When
purchasing at mom-and-pop stores, goods and products are used, while when
shopping large quantity as lower unit price at super centers, a large percentage is
wasted, and there is no savings in waste. The savings, when purchase at a mom-and-pop store is not in the unit price but is in what they don’t waste. An SMS is not
the lack of accidents, but what is not wasted on unknown processes.
Successful businesses keep a low inventory of products being held for sale. It is a
capital loss to keep a larger volume than what is expected to sell within a specified
time period. Large super complexes transfer their capital loss risk to customers by
offering lower unit prices with larger volume purchases required. Large super
centers have one definite purpose, which is to increase revenue and reduce losses.
A mom-and-pop store becomes an inventory storage location for customers,
where the store carries the capital losses of keeping products held for sale.
They offset these loses to some degree by higher unit sales prices than super centers
offer, but their customers still reduce their waste products and losses. At a mom-
and-pop store it is also possible to purchase special ordered items, while
customers is required to purchase what is sold at super centers. Principles of a
successful SMS are no different than the principles of a mom-and-pop store.
However, SMS enterprises are falling into a trap to delegate control of their SMS to
larger third-party organizations. A third-party SMS organization transfer their
hazards to individual SMS enterprises, and are without accountability to
operational processes. Hiring specialized consultants and SMS experts are necessary for SMS enterprises and is also a regulatory requirement for the triennial audit, but these consultants do not assert micromanagement control of the SMS.
The safety management system has developed into a super complex in safety that
very few comprehend. Large organizations set the stage of what an SMS must look
like and demanding the one-fit-all principle. Large organizations are conducting
comprehensive audits, and anyone who pass separate level are incorporated as
members with a compliance certification. SMS has become a system where the
focus for airlines and airports is to receive the highest possible certification and
remain in good standing with the auditor. What is excluded are how individual
airlines and airports operate with process that goes right day in and day out. SMS
enterprise receive a rating level of future expectations based on historical records
and regulatory compliance. While historical records are key performanceindicators are learning tools, they are incapable of providing future data for the
next day, next month or for the coming years.
Every SMS enterprise are
their own mom-and-pop
store. Whichever way an SMS
enterprise wish to look at it,
whatever recognition they are
longing for, or what group
and organization they belong
to, there are no competition
between SMS enterprises,
and they are still their own
independent and unique
mom-and-pop SMS store.
There are no two airports that are alike, and no two airlines with identical operations, but still, cloned process templates are applied to individual airports and airlines. An SMS cloudbased program with standardized requirements, is only applicable to regulatory requirements, which are operating in a static environment. A static environment is where a set of conditions, events, and surroundings that don’t change. In theory, a static environment doesn’t offer new or surprising elements, and does not adapt to operational processes. Operational processes must adapt to the static environment or conform to regulatory requirements. A static environment is any system that is intended to remain unchanged by users and administrators. The goal is to prevent or at least reduce the possibility of changes that could result in reduced security or functional operation. Each SMS enterprises must adapt and create their own unique
processes that conforms to regulatory requirements.
There is a difference between regulatory compliance and operational compliance.
Regulatory compliance is in a static environment, and operational compliance is in
a dynamic environment. An example of a regulatory environment is for an airport
operator to have a winter maintenance plan. A winter maintenance plan is
required by the regulations to be developed by the operator after consultations
with a representative sample of the air operators that use the airport.
In a regulatory environment
an airport operator invites
air operators to the
meeting, establishes an
agenda, and keeps detailed
minutes. An airport operator
may farm out the task, or
clone the tasks when
developing processes, but at
this point, there are no
actions initiated for the
airport operator to establish
operational compliance. The next step is for an airport operator to build processes that conform to regulatory requirements. Prior to the completion of processes, an
airport operator is in compliance with the static portion of regulatory requirements but remain in non-compliance with operational performance compliance until the process itself is fully completed. This delay, or gap, is the practical compliance gap.
A winter maintenance manual could be placed on the shelf and an airport operator
would still conform to regulatory requirements to have a winter maintenance plan.
Airports of similar size and complexity may have cloned winter maintenance plans
for regulatory compliance, but their regulatory conforming operational processes
are different based on services provided by the airport operator.
Just as a mom-and-pop store, each airport operator tailor their operations to the
needs of their customers, as opposed to demanding that air operators comply with
established services which suits the airport operator. Aprons, taxiways and
runways are different based on aircraft group number, and wingspan, tail height,
or approach speed. Airports tailor their operations to standard visibility, reduced visibility, or low visibility operations, based on an air operator’s need. A governing factor for airline requirements is aircraft size and distances between departure and arrival airports.
Airports of similar size and
complexity may offer
different services based on
the number of passengers
that are emplaned and the
number of passengers that
are deplaned at the airport.
Two independent airport may
both provide operational
service with a 9,000 FT
runway but may provide
different services based on
number of passengers. One
airport may provide a runway end safety area service, while the other airport decline to provide that service. Both airports are regulatory compliant in a static
environment since one airport has a higher number of passengers than the other, but their different level of service may cause airline operators to prefer the airport with a runway end safety area. In the same manner as mom-and-pop stores, different airports offer different services, but they cater to customers’ needs as opposed to demand that airlines use their airport because it is there.
An airport operator is required to maintain a regulatory compliant safety
management system (SMS) but is also required to maintain operational processes
which conforms to regulatory compliance. These are two distinct and separate
compliance requirements, since one is the regulatory static environment, and the
other is the operational dynamic environment. A regulatory compliant SMS manual
may be placed on the shelf and maintain its regulatory compliance status.
However, an airport operator remains within the regulatory compliance gap until
each operational process are completed with an outcome conforming to regulatory requirements. An operational process may be required to be performed
hourly, daily, weekly, monthly, or annually, which is dependent on services
provided by the airport operator.
Before taking off from, landing at or otherwise operating an aircraft at an
aerodrome, the pilot-in-command (PIC) of the aircraft shall be satisfied that there
is no likelihood of collision with another aircraft or a vehicle, and the aerodrome is
suitable for the intended operation. This regulatory requirement is applicable to
the pilot-in-command of an aircraft, but since an airport operator is required to
comply with the SMS regulations, it becomes a responsibility of an airport operator
to facilitate a level of service for the pilot-in-command to remain in compliance. A
rule of thumb for compliance with the SMS regulations, is when a requirement is
not stated in a regulation, that exactly the reason why an airport operator, as an
SMS enterprise, must develop their own processes founded in their safety policy.
Juts at the mom-and-pop stores providing individual service for customers, airport
operators have an opportunity to establish a level of service to assist pilots to
comply with their operational judgement requirement.
A safety management system includes a safety management plan, and the safety
management plan includes a safety policy, roles and responsibilities, performance
goals, a policy for reporting hazards, incidents and accidents, a policy under which
immunity from disciplinary action is granted, and a process for reviewing the safety
management. SMS requirements are unimaginable opportunities for an airport
operator to provide exceptional services to the airline and aviation industry. An
unwritten safety policy is a blank page to be filled with whatever an airport
operator decides, and include a non-punitive policy, roles and responsibilities, SMS
review and reporting. A safety policy may be closed for regulatory compliance, but
operational compliance are airport specific processes.
The savings when purchasing from a mom-and-pop store are reduction of waste
compared to purchasing large quantities at super complexes. A large jar of pickles
may come at a lower unit price at a super complex store, but when accounting for
the waste, the unit price is higher. Let’s say a large jar holds 50 pickles, while a mom-and-pop store jar holds 10 pickles. The unit price for 50 is 20 cents, while the
unit price for 10 is 50 cents. At first the 20 cents deal feels better. When
considering the waste, which are the number of pickles discarded plus pickles
consumed just because they are there. There will always be waste, and waste
often goes unnoticed and is not accounted for. With a new waste-calculation the
lower unit price at the end of the day cost a consumer five times more.
SMS waste are process deviations from expected outcome, or time spent on
unknown processes due to unfamiliar expectations. Cloned, and one-fits-all SMS
processes are encouraging SMS waste by enforcing expectations that are
unfamiliar to SMS operators. Within a mom-and-pop SMS, operational processes
are applied to regulatory requirements, as opposed to regulatory requirements
forcing operational changes. Mom-and-pop SMS also maintain a low inventory by
capturing drift, moving process back on the correct path, and spend minimum time
on irrelevant processes.
OffRoadPilots
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